Download Asbestos Survey Guidance - Southwest Clean Air Agency

 Asbestos Survey Guidance
Introduction
This document was developed to provide guidance on scope, structure, and content of an “Asbestos
Survey” and to serve as a field checklist for an asbestos survey. It is intended for use by local area
providers of asbestos surveys, abatement contractors, other regulatory agencies, and building owners.
The information contained in this document identifies what the Southwest Clean Air Agency (SWCAA)
deems is necessary for an acceptable “Asbestos Survey” and report for buildings, structures and vessels.
SWCAA 476-040 requires an “Asbestos Survey” before the renovation or demolition of a structure,
building or vessel. SWCAA defines an “Asbestos Survey” as “…an inspection using the procedures
contained in 40 CFR 763.86, or an alternate method that has received prior approval from the Agency…”
This EPA regulation addresses one sampling protocol with an emphasis on the number of samples to be
collected by an “Accredited Inspector” under different survey conditions, and a requirement for “random”
sample collection.
This guidance is also intended to clarify when an “Asbestos Building Inspector” is required for a survey,
destructive investigation, and minimal reporting requirements. This document is intended to assist
AHERA building inspectors on the construction considerations of the building being surveyed, inspection
scope, and sampling protocol.
GUIDELINES FOR AN “ASBESTOS SURVEY”
When an Asbestos Building Inspector is Required.
Asbestos Surveys for renovations and demolitions must be performed by an AHERA Building Inspector
as defined in 40 CFR 763 except for surveys associated with the renovations of owner-occupied singlefamily residences performed by the resident owner. For the renovation of such residences, homeowners
may perform their own asbestos surveys.
However, if an owner-occupied, single family residence is to be demolished, an AHERA Building
Inspector must be employed for the asbestos survey.
Purpose of Survey
Asbestos surveys are very much project specific. It is important that an asbestos survey be used only for
its intended purpose. For example, a limited survey conducted as part of a pre-purchase inspection is not
likely to meet the requirements of 40 CFR 763 and thus would not suffice as an asbestos inspection for
renovation or demolition. The purpose and limitations of any asbestos survey should be clearly
identified.
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Field Procedures
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Determine what materials were required for use under the Uniform Building Code in effect at the
time of construction and past renovations of the structure, if available.
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Review existing data including design drawings, as-built drawings, project specifications, and any
existing survey and/or laboratory information, if available.
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Use equipment that will allow visual examination of all accessible spaces.
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Confirm with the owner or owner’s representative the exact area under investigation, exact nature
of demolition/renovation and identify all material that may be disturbed or accessed.
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Determine whether the structure, building or vessel will be totally or partially renovated and/or
demolished.
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Determine and investigate each structure, building or vessel’s structural, mechanical, and roofing
systems that are to be disturbed.
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Perform a comprehensive investigation of areas to identify suspect materials to be sampled and/or
assumed to contain asbestos.
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Create a sample plan based on suspect materials present and requirements of 40 CFR 763.86.
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Collect bulk samples of all suspect materials that will be disturbed and not assumed to be asbestos
and submit them to a certified laboratory for analysis by polarized light microscopy (PLM). (A
“Suspect Asbestos Containing Material List” is included on the last page of this Guidance. Note
that this is not a comprehensive list of all potential Asbestos Containing Materials.)
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Document where all assumed asbestos materials exist and record their exact location, condition
and quantity. “Condition” shall include a physical assessment to determine whether or not each
assumed asbestos material is friable as defined by SWCAA 476-030.
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Also document all sampled materials found to be negative for asbestos, including original
location, condition, and quantity.
Destructive Investigation
Many asbestos containing materials are located in concealed areas such as wall cavities, below ground
level, and other hidden spaces. The Agency expects destructive investigation, as necessary, to gain access
to these hidden spaces and to inspect them for suspect materials. The following guidelines constitute
reasonable criteria for locating concealed materials:
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Identify the different structure, building or vessel systems which may involve concealed suspect
asbestos materials such as the heating/cooling system, domestic water lines, roof drainage lines,
miscellaneous piping lines, underlying roofing, etc.
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Open hidden areas and inspect each system in at least three (3) locations for each area of
construction.
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Focus the inspection on likely areas for suspect materials (i.e. where insulated pipe enters walls or
ceilings, behind heating units, etc.).
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Destructive Investigation continued
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Examine additional areas if results of inspection are inconsistent.
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Clearly list all concealed areas which have not been inspected, and explain why they were not
inspected. Reasons why may include: (1) records showing recent access to such spaces and
sample results, (2) safety hazards, and (3) restrictions imposed by the property owner.
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For those asbestos surveys that include inaccessible concealed spaces, a qualified person should
be available during the project to address the potential of unidentified suspect materials becoming
disturbed once work begins.
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AHERA Building Inspectors may discuss with the property owner the possible need to disconnect
electrical power or other utilities during the destructive phase of the investigation. It may also be
desirable for the property to be unoccupied.
Survey Report Format and Content
The survey report should list the results of the asbestos survey in a manner easy to understand. The
survey report should also contain an introductory summary that briefly explains what will be found in the
report. Documentation such as field data sheets and photographs should appear in the appendices of the
report.
Background Information & Scope of Work:
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Date(s) of field inspection
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Date of report submittal
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Structure, building or vessel address
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Structure, building or vessel owner including address and contact person
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Description of area surveyed including any exclusions or limitations (be specific)
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Description of structure, building or vessel status after survey, if known (will the building be
totally or partially renovated and/or demolished?)
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Name of the report writer(s) and reviewer(s) including AHERA accreditation information
Building Description:
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Structure, building or vessel name, if any
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Type of structure, building or vessel i.e. commercial, industrial, marine, warehouse, retail
residential, etc.
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Special features of structure, building or vessel
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Type of business
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Approximate age of structure, building or vessel and dates of past renovations
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Description of building systems such as structural system, mechanical system, roofing system,
nonstructural systems (not inherent to structure, building or vessel), etc.
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AHERA Building Inspector / Firm Affiliation / Laboratory Information:
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Names(s) of AHERA Building Inspectors(s) including certification number, inspector’s signature
and expiration date
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Inspector firm information including name, address, and phone number
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Laboratory name and accreditation
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Special instructions regarding type of analysis requested such as PLM, point counting, TEM
Survey Methodology:
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Describe the inspection procedure being used, including the scope of the survey. The inspection
must be in accordance with the sampling protocol in 40 CFR 763.86, as required by SWCAA
476-040.
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Inventory the locations of homogeneous areas where samples are to be collected
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Describe the sample methods employed
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If hidden or inaccessible areas are to be disturbed or are likely to be disturbed, provide a detailed
description of the procedure used to find hidden suspect materials, (for example, if asbestos pipe
insulation is suspected in a wall cavity, describe by location, where wall was opened for
examination). The Agency recommends that each building and non-structural (not inherent to
building) system suspected of having asbestos containing materials be breached and sampled at a
minimum of three locations.

Highlight in the inspection report any concealed areas that were not surveyed and that may
contain undiscovered asbestos containing materials.
Asbestos Identification Process:
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Prepare a sample and suspect asbestos material location plan
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List all materials sampled and tested, including test results and date(s) collected

List all suspect materials assumed to contain asbestos; be specific in terms of quantity and
location of material

List whether homogeneous areas identified are surfacing material, thermal system installation, or
miscellaneous material and indicate the amount of suspect materials sampled; be specific

Describe the exact location where each bulk sample is collected and the assessment of friability
including reasons for assessment.
Procedure for Communicating Survey Findings to Affected Parties
The AHERA Building Inspector should assist the property owner in communicating both verbally and in
writing the survey results (copy of survey report) to persons who may come in contact with any identified
or suspect asbestos containing materials. Such persons may include contractors, subcontractors, building
occupants/guests/visitors, custodial and maintenance staffs, occupants of neighboring buildings, etc.
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Suspect Asbestos-Containing Material List.
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Window Glazing
Stucco
Cement Pipes
Cement Board/Transite
Duct Tape/Paper
Furnace Insulation
Vinyl sheet Flooring/Mastic
Vinyl Floor Tile/Mastic
Wallboard
Poured Flooring
Pipe Insulation/Fittings
Plaster/wall Joints
Textured Paints/Coatings
Vinyl wall coverings
Ceiling Tiles/Panels/Mastic
Spray-applied Insulation
Blown-in Insulation
Fireproofing materials
Sink Insulation
Packing Materials
High Temperature Gaskets
Lab Hoods/Table Tops
Fire Blankets
Fire Curtains/Hose
Laboratory gloves
Elevator Brake Shoes
Asphalt Flooring
Paper on backside of Fiberglass Insulation
Laboratory Fume Hoods
Flooring backing
Elevator Equipment Panels
Thermal paper products
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Paper Fire Box in Walls
Fire Doors
HVAC Duct Insulation
Boiler/Tank Insulation
Breaching Insulation
Ductwork Flexible Connections
Construction Mastics
Acoustical Ceiling Texture (“popcorn”)
Spackling compounds
Electrical Panel Partitions
Electrical Cloth
Electrical Wiring Insulation
Chalkboards
Roofing felt
Roofing Shingles
Built-up Roofing
Base Flashing
Rolled Roofing
Caulking/Putties
Incandescent Light Fixture Backing
Joint Compound/Wallboard
Brick Mortar
Vinyl Wall Coverings
Vapor Barrier
Cement Roofing Shingles
Gray Roofing Paint
Nicolet (white) Roofing paper
Sub-flooring Slip Sheet
Mudded Pipe Elbow Insulation
Acoustical and decorative plaster
Cooling towers
Adhesives
Note: This list does not include every product that may contain asbestos. It is intended as a general
guide to show which types of materials may contain asbestos.
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